What Are the Odds? Lower Compliance with Western Loot Box Probability Disclosure Industry Self-Regulation Than Chinese Legal Regulation

This study examines whether industry self-regulation of loot box probability disclosure in the United Kingdom achieves compliance rates comparable to the legal regulation mandated in the People's Republic of China. Its central argument is that voluntary, non-enforced disclosure schemes are less effective than statutory requirements, and that UK policymakers should consider making probability disclosure a legal obligation. The authors position loot boxes as randomised rewards structurally akin to gambling, noting their substantial revenue (global spending estimated at US$15 billion in 2020) and their potential to expose young players to gambling-like harms.

The empirical work surveyed the 100 highest-grossing iPhone games on the UK Apple App Store on 21 June 2021. Of these, 75% contained first-party loot boxes, a prevalence not significantly lower than the 59% recorded in early 2019 and, in fact, significantly higher. Of the 75 games with loot boxes, 64% disclosed drop probabilities as Apple's self-regulatory guidelines require, compared with a 95.6% compliance rate previously observed in the PRC, a difference the authors report as statistically significant. Disclosures were most often placed in-game rather than on official websites, and the study catalogues eight in-game and four website subcategories by prominence and accessibility, finding that most were not easily reachable. A subsample of titles available in both markets reached a 94.3% disclosure rate, which the authors interpret as possible spillover from PRC law into UK releases.

The study's scope is limited to one platform, one national storefront, and a single snapshot in time, and its conclusions about regulatory effectiveness rest on cross-jurisdictional comparison with earlier data collected by the same research group. The preregistered design, with data and analysis openly available, strengthens confidence in the reported figures.